Nearly three years have passed since the Occupational Safety and Health Administration's (OSHA's) revised crane regulations became effective. The rules (29 CFR 1926.1400-1442, Subpart CC) have had a significant effect on material handling operations during roof system removal and installation.
OSHA's new crane standard came about as the result of a negotiated rule-making process. In such an approach, stakeholders from various groups, including OSHA staff, attempt to develop a consensus document for submission to the agency and, if approved, it is published as a proposed rule for public comment.
Negotiated rule making often is seen as a less adversarial process that fosters a more balanced approach. The anticipated result is the rule will be more readily accepted and generally easier to enforce; essential to this is the agency acceptance of the consensus of the rule-making committee. But a number of key provisions in the crane regulations remain areas of contention for construction trade groups.
Subpart CC's primary component requires operators of equipment covered by the rule to be certified, qualified or licensed—with each alternative having specific OSHA demands, restrictions and drawbacks.
For example, though an option is provided for qualifying an operator through an audited employer program with written and practical examinations of operator knowledge and skills, the extensive developmental and auditing costs to a roofing contractor effectively eliminate this option.
However, the upside of this, in some contractors' views, is this form of qualification is not portable, meaning the qualification would not be valid at other places of employment.
Crane operators certified by accredited crane operator testing organizations also must pass written and practical tests specifically developed and administered for the type and capacity of equipment operated. This option also means substantial costs to a roofing contractor for training and certification fees paid to third-party providers. Operator certification under this alternative is fully portable.
The third alternative, licensing by a government entity, involves a government licensing department that OSHA considers an accredited testing organization for crane operators if certain conditions are met. Conditions include an assessment of an operator's knowledge and skills using written and practical tests; test criteria and administration that meet industry standards; continued operator education; and skills development ensured through relicensing.
Licenses are valid for a time frame not to exceed five years, and a license only covers equipment operation within the jurisdiction of the government entity issuing the license. However, OSHA has noted government licensing that meets the requirements would be portable.
For all crane operator credentialing methods, a high level of operator skill and knowledge is ensured through the third-party oversight components in the OSHA regulations.
The crane rule carves out an exclusion from Subpart CC requirements for boom trucks with articulating or knuckle booms that deliver sheet or packaged material to a construction site if the truck has a functioning overload-prevention device.
The exclusion does not apply to boom trucks with straight booms (common in roofing operations) though such equipment regularly performs similar deliveries and ordinarily is equipped with identical safety features. This is a significant distinction because equipment covered under Subpart CC must be operated by a qualified, certified or licensed operator as previously discussed. Operators of excluded equipment need not complete such a rigorous certification or qualification process.
Some limited-capacity equipment also is excluded from the operator certification, qualification or licensing requirements if it has a rated capacity of 2,000 pounds or less. This exclusion would apply to hoists, such as swing beam hoists, that are used on roofing job sites. Operators still are required to be trained on the particular type of equipment under OSHA rules, but no formal credentialing is needed. However, on many projects, hoists are not capable of performing the required tasks with the efficiency of a mobile crane or boom truck.
In these cases, operator credentialing by an accredited testing organization can be a valuable distinction that sets a company apart from competitors, enabling a company with a credentialed operator to bid on jobs its competitors cannot.
Qualified signal person
OSHA requires a qualified signal person in three circumstances:
Practically speaking, this means a signal person is required in nearly all instances of crane operation in roofing situations. OSHA states the qualification requirements of a signal person can be evaluated by a third party or an employer's qualified evaluator. As a result, the training and evaluation can be done in-house for significant cost savings. If a signal person is evaluated by a co-worker, which ordinarily will be more cost-effective, the signal person's qualification is not portable. If a roofing contractor relies on a third-party qualified evaluator as defined by OSHA, signal persons would receive portable qualifications.
Workers must demonstrate the following qualification requirements through successful completion of oral or written practical tests:
It is important to remember that even though some equipment regulated by OSHA does not require formal operator credentials, use of a qualified signal person often is required. For example, a hoist of 2,000 pounds or less rated capacity does not require a certified or qualified operator under Subpart CC but operations likely would demand use of a qualified signal person.
OSHA requires a qualified rigger whenever workers are within the fall zone of a load while hooking, unhooking or guiding the load or connecting the load to a component or structure. For all practical purposes, most general contractors, building owners and roofing contractors implement this rule broadly—requiring a qualified rigger whenever a crane is in operation without regard to the nature of the lift and presence or absence of workers in the fall zone.
OSHA does not specify qualifications a rigger must possess. But the definition of a qualified rigger demands a recognized degree, certificate or professional standing or extensive knowledge, training and experience along with a demonstrated ability to solve problems related to rigging.
This is an assessment a roofing contractor can establish solely as an internal procedure or through the use of a third-party provider who would deliver the appropriate rigging training content and evaluate workers' knowledge, understanding and proper implementation of rigging procedures. Naturally, all assessments of qualifications with respect to riggers whether in-house or third party should be documented and retained.
Certified forklift operators
Although a large amount of roofing material is moved at job sites with cranes or hoists, forklifts also are used extensively to move equipment and materials at roofing warehouses and job locations. OSHA states an employer must certify each operator has been trained and evaluated for competence in operating a powered industrial truck (forklift) before allowing an operator to drive a forklift (except for training purposes).
OSHA sets out specific training and evaluation topic areas with respect to forklift operation, workplace conditions, travel rules, and loading and maintenance procedures that must be part of the operator certification process under 29 CFR 1910.178.
Many roofing contractors use third-party training providers to satisfy OSHA requirements for certification. OSHA does not require independent trainers for this process, and many contractors can save significant amounts of training expenses by handling the certification process in-house.
The bottom line
Material handling training provides opportunities for roofing contractors to save substantial money by delivering training and certification programs in-house. Where this is less appropriate, as in the case of boom truck operators, a roofing contractor must be cautious when selecting third-party trainers to qualify or certify operators. Trainers with accreditation from a recognized national crane operator testing organization should be selected but not before checking references.
Harry Dietz is NRCA's director of risk management.
Did you know?
The recently issued NRCA Material Handling Series: Overhead and Understood provides information about the latest OSHA requirements related to crane and hoist operations, signal person qualifications, qualified riggers, forklift operations and working with rooftop powered equipment.